Poland Advances Digital Tax Reporting: New JPK_V7(3) VAT Structures and Draft JPK_MAG(2) Released

Poland's Ministry of Finance is continuing the rapid evolution of its digital tax compliance landscape, simultaneously releasing critical updates to two separate Standard Audit File for Tax (SAF-T), or JPK, structures.
These parallel developments impact both mandatory VAT reporting and on-demand warehouse audits, requiring businesses to prepare for significant technical adjustments in the coming years.
New JPK_V7(3) Structures for VAT Reporting
In a move set to impact all VAT-registered entities, the Ministry of Finance has published working versions of new logical structures for VAT reporting. These new structures are:
- JPK_V7M(3) (for monthly filers)
- JPK_V7K(3) (for quarterly filers)
These new versions are scheduled to replace the current JPK_VAT with declaration (JPK_V7M/K(2)) format. The target implementation date for this mandatory switch is February 2026.
This update signals a further refinement of Poland's comprehensive VAT reporting system, requiring businesses and software providers to analyze the new schema and plan for necessary updates to their ERP and accounting systems well ahead of the 2026 deadline.
Draft JPK_MAG(2) for Warehouse Operations
Separately, the Ministry has addressed another key component of the JPK framework: warehouse operations. A draft version of the updated logical structure for the JPK_MAG (Standard Audit File for Warehouse Operations), designated JPK_MAG(2), has been released.
Unlike the daily JPK_V7 file, the JPK_MAG is typically provided "on-demand" at the request of tax authorities during an audit. This new draft aims to update and likely expand the data points required for warehouse reporting.
The Ministry of Finance has invited public feedback on the proposed JPK_MAG(2) structure. This public consultation period is open until November 12, 2025, allowing stakeholders to submit comments and suggestions on the draft before it is finalized.
What This Means for Businesses
With a firm deadline for JPK_V7(3) in 2026 and a new JPK_MAG(2) structure on the horizon, businesses operating in Poland must maintain a clear focus on their tax technology roadmap. Companies will need to engage with their compliance partners and IT departments to ensure their systems can manage these new structures to remain fully compliant with Poland's evolving digital tax requirements.
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